Santa Susana Field 

Laboratory (Area IV) 

SEC Petition-00235 Followup Items

Presented by: 

Bob Barton, SC&A, Inc.

Meeting of the Advisory Board on Radiation and Worker Health

Pittsburgh, PA

August 21, 2019
Remaining Petitioner Concerns

 Advisory Board requested that SC&A formally 

respond to two main issues raised by CORE 

Advocacy during Meeting 128 in Pittsburgh, PA:

 Historical Site Assessments developed for the EPA in 

2012 indicate numerous site areas where americium 

and/or thorium are listed as radionuclides of concern

 Specific Site Assessment for Building 4023 indicated 

involvement in TRUMP-S* activities after the end of the 

SEC-00234 period (i.e. post-1988)

*Transuranic Management by Pyropartitioning-Separation

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Historical Site Assessments

 Stated purpose of the Historical Site 

Assessments:

“The objective of the HSA component of the radiological study 

was to provide a comprehensive investigation that identifies, 

collects, organizes, and evaluates historical information 

relevant to nuclear research operations as it pertains to 

radiological contamination in the Area IV Study Area. Once 

these areas were identified, potential areas where radiological 

contamination may exist at the site were identified for 

sampling.” 

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Historical Site Assessments (cont.)

 SC&A examined the 2012 Site Assessments for 

evidence of operational work involving thorium 

and americium.

 SC&A specifically addressed each area identified 

by the petitioner in CORE Advocacy’s 2017 

report: Locations of Americium/Thorium/ 

Associated Progeny and Approximate Dates of 

Building Demolition.

 Results of SC&A’s investigation are detailed in 

the July 2019 memo: Evaluation of PetitionerSpecific Concerns Regarding SEC-00235.

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Historical Site Assessments (cont.)

 SC&A found no evidence of operational activities 

involving americium and/or thorium occurring after 1988.

 Site areas identified by CORE Advocacy:

 Area underwent D&D prior to 1989 (16 identified areas, ~33%)

 Area only included due to the proximity to another facility that 

historically handled Th-232/Am-241 (10 identified areas, ~20%)

 Operational activities potentially involving Am-241 and Th-232 

occurred prior to 1989 (10 identified areas, ~20%)

 Area served as a storage facility only (6 identified areas, ~12%)

 Area no longer in use after 1988 or demolished (5 identified areas, 

~10%)

 Area handled sealed sources only (1 identified area, ~2%)

 Area did not handle Th-232/Am-241 (1 identified area, ~2%)

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TRUMP-S Activities in Building 4023

 Historical Site Assessment for Building 4023:

“In 1989, reports appear to indicate that Building 4023 

served as a support facility for the Transuranic (TRU) 

Management by Pyropartitioning – Separation (TRUMPS) operations in Building 4020, located in Subarea HSA5D. Atomics International requested DOE’s approval to 

utilize the facilities for a 2-year period beginning July 

1988 for the Kawasaki Heavy Industries (KHI) and the 

Central Research Institute of the Electric Power Industry 

(CRIEPI) of Japan-sponsored “pyrochemical partitioning 

of actinides from PUREX waste” program. . . . The 

material used in this experiment was listed as including 

uranium, neptunium (Np-237), plutonium (Pu-239), and 

americium (Am-241).”

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TRUMP-S Activities in Building 4023 (cont.)

 October 1988: Internal letter identifying deficiencies in the 

proposed usage application for TRUMP-S materials.

 July 1989: Internal letter documenting a planning meeting 

related to documentation required for the proposed 

TRUMP-S glovebox in the hot lab.

 Undated Report (likely mid-1989): “A meeting was held 

with [redacted] to discuss the disposition of the waste to 

be generated from the TRU partitioning tests. Since 

the waste will contain transuranics (Pu, Am, Np) and 

cadmium, the waste generated in late 1989/early 1990 will 

be TRU/mixed waste. [Redacted] will be in contact with 

[Redacted] to determine what steps are needed to get a 

head start on the planning/disposal process.” [Emphasis 

added.]

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TRUMP-S Activities in Building 4023 (cont.)

 October 1989: Internal letter states that a Test Readiness 

Review is to be held for the TRUMP-S glove box tests

 October 1989: Internal letter containing meeting minutes 

related to the TRUMP-S program: “The following action 

items resulted at the meeting. These action items must be 

completed prior to beginning the radioactive portion of 

TRUMP-S.” [emphasis added]

 February 1990: Letter from Rockwell International to the 

NRC: “This is in reply to your letter . . . regarding our 

recent transmittal to [redacted], wherein we provided 

additional information regarding the TRUMP-S program to 

be conducted in the RIHL.” [emphasis added]

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TRUMP-S Activities in Building 4023 (cont.)

 February 1990 technical progress report notes: 

“While Rockwell was awaiting DOE permission to 

start up the test pending DOE review of the NEPA 

Action Description Memorandum, Rockwell 

Management concluded it would be impractical to 

continue the TRUMP-S project beyond Stage 1 

activities at the Santa Susana Field Laboratories. As 

a result, an effort was undertaken to locate a facility 

where the TRUMP-S actinide tests could be 

conducted for both Stage 1 and Stage 2.” [Emphasis 

added.]

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TRUMP-S Activities in Building 4023 (cont.)

 February 1990: newspaper article describes the filing of 

legal cases by opponents to the TRUMP-S program: 

“The cases challenge Rocketdyne’s record of credibility in 

monitoring itself, the company’s described “worst-case scenario” for 

its planned “TRUMP-S” project, its emergency contingency plan, 

and several other aspects of the company’s application. . . .

[Rocketdyne] is seeking permission to keep the lab open through 

Oct. 30 to complete one last experiment called TRUMP-S, for 

transuranic management by pyro-partitioning separation, and has 

announced plans to shut it down afterward.

Originally, Rocketdyne was seeking a 10-year license extension, 

but cut its request to one year last October.” [Emphasis added.]

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TRUMP-S Activities in Building 4023 (cont.)

 May 1990 newspaper article:

“Rocketdyne announced in April that the “hot lab’s” days were over. 

One last experiment called TRUMP-S, originally scheduled to 

take place in the “hot lab,” was relocated to University of 

Missouri, at Columbia in the heat of public challenges to the 

company’s request to get the project licensed by the U.S. Nuclear 

Regulatory Commission.

The experiment would have been in a 4-by-3.5-by-7-foot shielded 

glove box.

Now the TRUMP-S project — sponsored jointly by Japan and the 

DOE – is facing challenges in Missouri as well. But Rocketdyne

officials are confident that the project will go forward there.” 

[Emphasis added.]

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Conclusions

 SC&A’s conclusions remain unchanged from those presented 

to the Board during Meeting 128 in Pittsburgh, PA:

 2012 Historical Site Assessments indicate numerous site areas 

and existing structures where the potential for residual 

contamination exists (including americium and thorium)

 Evidence suggests the radiological portion of the proposed 

TRUMP-S experiments never occurred at SSFL though significant 

planning and licensing steps had been taken

 SC&A found no evidence of operational activities occurring at 

SSFL post-1988 involving americium and thorium

 Dose reconstruction methods for exposure to residual levels of 

americium and thorium during D&D activities are under 

development by NIOSH

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Questions?

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